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UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF MAINE 



NATIONAL ORGANIZATION FOR 

MARRIAGE and 

AMERICAN PRINCIPLES IN ACTION, 

Plaintiffs 



WALTER F. MCKEE, ET AL. 

Defendants. 



Civil No. l:09-cv-00538 



NOM Deposition Exhibit 12: 

"National Strategy for Winning the Marriage Battle," 

dated December 15, 2009 



[THIS DOCUMENT WAS PREVIOUSLY FILED UNDER SEAL AS DOCKET ITEM 132-2] 



NOM Deposition Exhibit 12: 

"National Strategy for Winning the Marriage Battle," 
dated December 15, 2009 



National 
Strategy for 
Winning the 
Marriage 
Battle 




Prepared by the National Organization for Marriage 

December 15, 2009 



National Organization for Marriage 

Brian S. Brown, Executive Director 

2029 K Street NW, Suite 300 

Washington, DC 20006 

Phone: (202) 457-8060 

Email: bbrown@nationformarriage.org 

www.NationForMarriage.org 



Confidential 



GD 

NATIONAL 

ORGANIZATION 
FOE MARRIAGE 



Kati^nal Strategy; cfbr WimirigAe'Mamag^aattl^ 



Table of Contents 

A National Strategy for Winning the Marriage Battle • •. 4 

The Stakes : ... ; > • • •;■■" 5 

Can We Win? , •■ •; ; " 5 

Marriage: A Strategy for Victory • • • 8 

1 . Fall 2009.: Testing the Model Victories in New York, New Jersey and Maine 8 

New York/New Jersey : '• • ** 

Maine - • • y 

2. 2010 Priority: Roll Back Gay Marriage in New Hampshire. Iowa and D.C .':.. 10 

New Hampshire • H 

. District of Columbia , • r - •. - •; ** 

Iowa ■*-— * 2 

3. Going on Offense ■ • •' 12 

The Pennsylvania and Beyond Project , ■■ 13 

NOM Rhode Island ...„ , 13 

Two Million for Marriage , • ■•••'• * 5 

State Emergency Reserve Fund " 

Federal Marriage Political Action Committee ; 16 

4. The International Organization for Marriage 16 

5. NOM Legal Defense Fund :'. • 17 

6. Cultural Strategies 18 

The Latino Project: A Pan-American Strategy - • 19 

' The Next Generation Leaders Project • 20 

"Not A Civil Right" Project - ••• 21 

Expert Witness Project • > 22 

Catholic Clergy Project 23 

3 

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National Strategy for Winning the Marriage Battle 



Behind Enemy Lines: Document the Victims— Keeping Gay Marriage Controversial in 

Massachusetts, Vermont,, and Connecticut .». ■•—», v 23 

The Face of the Victims: Rapid Response Video Team arid Archive „ ;.... 24 

Gay Rights or Parents' Rights? An Exploratory Project : - 25 

Achieving NOM's $20 Million Strategy for Victory , - 26 

Budget & Fundraising (July 2009 to Dec. 2010) • •'••• 28. 

$20 Million for Marriage Fundraising Plan •• • * • 29 

Major Donors • • ^0 

Private Phases - • • ^L 

Public Phase : 31 

How Can We Possibly Do All This? A Note to Donors ...: 31 

References * • • • — ' 34 



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National Strategy for Winning the Marriage Battle 



A National Strategy for Winning 
the Marriage Battle 

Marriage, will be won or lost in the United States in the next two to three years, and victory in the 
United States will depend primarily on adequate resources. From a political angle, this strategy 
wi 11 require electing a pro-marriage president in 20 1 2. 

The National Organization for Marriage (NOM) has emerged as the national party of marriage, the 
only single-issue national organization making substantial investments in marriage fights in every 
state. Since its formation in July of 2007, NOM has helped win key victories in California, Maine, 
New York and New Jersey. NOM emerged as the largest single investor in Prop 8 in California, 
putting in key early money mat helped get Prop 8 to the voters. In Maine, NOM provided more 
than half the budget needed to overturn gay marriage. 

Since January 1., 2009, NOM's small donor base has nearly quadrupled, from 8,000 to 30,000 and 
its activist constituency has increased, tenfold from 50,000 to over 500,000 (The goal is 50,000 
donors and 2,000,000 activists by the end of 2010.) . 

In the United States, we've demonstrated a key fact: with adequate resources, we can win the battle 
for hearts and minds on the marriage issue. We can use what we've. learned about winning this 
battle to protect marriage internationally as well. 

To win the fight for marriage, NOM planned to' raise over $20 million between July 1, 2009 and 
the November 20 1 elections. Since launching the $20 million victory fund in July of 2009, NOM 
has raised (received or pledged) $7.5 million of that $20 million as of December 1, 2009. 



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National Strategy for Winning the Marriage Battle 



The Stakes 

Marriage is a cornerstone of every known civilization. High rates of family fragmentation 
drive enormous public costs. 1 An antifami'Iy culture affects economic performance, expands the 
regulatory and taxing powers of government, and threatens the family businesses that generate 
economic growth and prosperity. 

Gay marriage is the tip of the spear, the weapon that will be and is being used to marginalize and 
repress Christianity .and the Church. 2 What does. the gay maniage idea mean once government' 
adopts it? It means faith communities that promote traditional families should be treated in law 
and culture like racists. It means that the authority of parents to transmit moral values to children 
will be eroded. 



Can We Win? 

The current state of despair over the future of marriage is manufactured, a weapon in our opponents' 
hand. Our U.S. experience is that victory is possible, even likely, provided we have the resources 
to fight this battle. (This is why gay marriage advocates have focused relentlessly on harassing 
and intimidating local donors, trying to cut off the debate by limiting resources 3 and why one key 
advantage we. now have is the capacity to protect th e identity of our donors.) 

The National Organization for Marriage (NOM) and our allies have won key victories both in 
courts of law and at the ballot box. 4 

Gay marriage has lost 3 1 out of 3 1 times when put to voters— not only in culturally and politically 
conservative states like Louisiana (78 to 22 percent) and Alabama (81 to 19 percent), but also in 
progressive, liberal states like Wisconsin (59 to 41 percent) and Oregon (57 to 43 percent). 

In November of 2008 in California, one of the most liberal states in the U.S., the majority again 
rejected gay marriage, as did voters in Florida (62 percent to 38 percent) and Arizona (56 to 44 
percent). Just this November in another liberal state, the state of Maine, voters once again rejected 
gay marriage, this time by a margin of 53 percent to 47 percent. 



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National Strategy for Winning the Marriage Battle 



The latest Gallup poll shows that, more than six years after gay marriage first became a national, 
issue, most Americans continue to oppose gay marriage (57 percent to 40 percent). By amargin of 
four to one, Americans are more' likely to believe gay marriage will hurt our society (48' percent) 
than make society better off (13 percent). 5 

Despite several recent high-profile court victories, the majority of U.S. courts have rejected the 
idea that gay marriage is a constitutional right, including the high courts of New York (2006), 
Washington State (2006), New Jersey (2006) and Maryland (2007). "We contributed by organizing 
highly respected scholars to sign onto amicus briefs supporting marriage in each of these cases, and 
we will continue to perform that role in the crucial same-sex marriage litigation moving forward. 6 

We have learned much about how to win the marriage battle. What we need now is to find the 
resources to prosecute and expand this strategy to win marriage in the U.S., and to expand it into 
a global movement. 



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National Strategy for Winning the Marriage Battle 



Marriage: A Strategy for Victory 

Our goal is to use a victory in the U.S. to launch a global movement to reverse the tide on cultural 
and legal respect for core family values like marriage. 

Our strategy for victory includes: 

1. Fall 2009: Testing the Model 

Victories in New York, New Jersey and Maine 

New York / New Jersey. 

Gay marriage lost at the ballot box and in key state legislatures in the fall of 2009. NOM invested 
more than $1.2 million in voter outreach in New York and New Jersey, contacting voters and 
asking them to call their legislators. The result was an unprecedented flood of phone calls urging 
legislators to vote against gay marriage. For example, Sen. Joseph Addabbo, a Democrat from 
Queens, told the New York Times that three-quarters of phone calls from his New York City 
district were from voters opposing gay marriage. 7 Along with NOM's media campaign, and our 
strategic investment in a special election in New York's 23rd congressional district (where half the 
. voters who rejected pro-gay mat riage Republican Dede Scozzafava for a third-party candidate said 
her vote for gay marriage was a significant factor), NOM's sophisticated voter outreach produced 
a surprising, unexpectedly large, lopsided rejection of gay marriage in the New' York Senate (38 
no to 24 yes). 8 

In New Jersey, gay marriage advocates had publicly promised they would pass gay marriage in 
the lame duck session this fall. Yet once again, NOM helped engineer a surprisingly powerful 
outpouring of public objections from ordinary voters: gay marriage supporters were forced pull the 
bill in the Senate. 9 Gay marriage advocates are currently seeking a way to pass the bill through the 
Assembly, but their prospects look, dim^ as of this, writing. 

■In both states, NOM worked closely. with local leaders, including the Catholic Conference and 
evangelical family groups who also deserve credit for the victory. 



Confidential 



eternal Strategy Sr Whining the Marriage Battle; 



Here's the bottom line: NOM's model for influencing not only referendums but legislatures by 
adding, sophisticated messaging and political know-how to the efforts of local groups has been tested 
and found, to be an effective use of resources. Against every prediction, and all the. conventional 
wisdom, marriage is winning. 



In 20 1 0, NOM will follow up on these victories by demonstrating the capacity to educate voters in 
New York and New Jersey in the run up to the November elections. 



NOM 2009-2010 BUdgiefo MeWYmkimw JStfs^ 

201 £i Need..,, „,»,.,*.<..-..-, 



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Maine 

In November, the people of Maine decisively rejected a gay marriage bill passed by their own 
legislature, by a margin of 53 percent to 47 percent. Pundits were shocked, because gay marriage 
advocates went into this battle with extensive advantages: Maine is a relatively secular, socially 
liberal state with a history of successful pro-gay referenda; they had athree-year head start, investing 
millions in building a political machine that could both pass gay marriage and defend it at the ballot 
box. They had the advantage of learning the so-called lessons of California, running a strategically 
more competent messaging campaign. They raised substantially more money, outspending the 
traditionalists two to one. Maine has very few African-Americans, and the Mormon Church was 
riot involved in any major way. Arid yet gay marriage, advocates woke up on the Wednesday after 
the election to find gay marriage had lost by an even bigger margin than in California: 

NOM was intimately involved in Maine from the beginning, helping create and manage the 
StandforMarriageMaine.com referendum committee, collecting twice as many signatures as 
necessary to get gay marriage on the ballot, and ultimately funding almost two-thirds of the 
campaign ($1.8 million of the approximately $3 million raised). The Maine victory proved critical 
to stopping the momentum, of same-sex marriage in the Northeast. NOM had originally budgeted 
$1 million for this campaign, but when fundraising from other sources failed and the campaign 
was faced with having to severely cutback its media buys, NOM stepped in from general revenues 
to provide an unbudgeted additional $'800,000. No other national organization provided anything 
like the financial support NOM. did. 



10 



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National Strategy for Winning the Marriage Battle 



Marriage is not only NOM's highest priority, it is our only priority. Because we have no competing 
funding priorities, we can funnel/resources as needed to win marriage rights. 

The great Victory in Maine punched a hole in the cultural narrative of defeatism that even too 
many Christians had begun to accept. It helped pave the way for a Victory in New York and New 
Jersey, and also helps in the ongoing litigation which will end up in the Supreme Court by making 
ongoing public opposition to gay marriage crystal clear. 



2009*2010 Budget: IVIaine~$01 (c)(4). 
2010 Need. , ....:.. 



..^$1*80^000 

$0 



2. 2010 Priority: Roll Back Gay Marriage 
m New Hampshire, Iowa and D.C. 

Beginning in 2009 and through 2012, NOM's goal is to roll back same-sex marriage where it has 
been imposed by courts- or enacted by legislatures (Massachusetts, Connecticut, Vermont, New 
Hampshire, District of Columbia and Iowa). 

New.Hampshire and Iowa are the two states that have directimplications for the 201 2 presidential 
elections, and they also happen to be the states with the greatest possibility for victory, the District 
of Columbia has an initiative and referendum process (similar to California and Maine) that allows 
for the possibility of taking the issue directly to a vote of the people (although court battles will be 
necessary to achieve this end— see more below). Therefore NOM's top priorities for rolling back 
gay marriage in 201 will be New Hampshire, Iowa, and the District of Columbia. 

A note on the strategic significance of New Hampshire and Iowa: Marriage needs to be a national 
(and ultimately international) effort, not just a local or regional issue. If marriage is going to be 
preserved as between a man and a woman in the United States, the next president must be a man 
or woman who expressly articulates a pro-marriage culture, and appoints sympathetic Supreme 
Court justices. 



11 



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National Strategy for Winning the Marriage Battle 



New Hampshire 

Passage of same-sex marriage in New Hampshire has brought Democratic Governor John Lynch's 
election numbers down to the lowest point in his entire terra. We are working with Republican 
Party chairman and former Governor John Sunttnu to implement a plan to defeat Governor 
Lynch and flip both houses of the legislature. Through a state political action committee, we have 
already helped defeat one pro-same-sex marriage candidate in a special, election. We are targeting 
100 House districts and 10 Senate districts. The overall budget for our part of this effort is $2 
million— $1 million to defeat Lynch and $1 million to flip the legislature. 



In New Hampshire, if we can elect a new legislature and governor we can reverse gay marriage 
quickly, either directly or by a quick referral to a vote by the people in 20 1 1 . 



NOM J200&.2Q16 Bpdgfetr New-Hani; 

2010 Need ,„.,....,.,., ..<„ 



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$2,000,000 

.....,$.1,600,000 



District of Columbia 

The D.C. City Council has just passed a gay marriage bill, over the objections of Archbishop 
Wuerl and a coalition of black pastors led by.Bishop Harry Jackson. In 2009, NOM helped create 
and manage Stand for Marriage D.C. and brought Schubert Flint. Public Affairs in to help lay the 
groundwork for an initiative and referendum campaign. In 2010, getting marriage to the people 
of D.C. wiJl involve litigation as the first step (since the D.C. Board of Elections claims that 
the measure Would violate the Human Rights Act, which cannot be amended by a vote of the 
people). The legal outcome is never certain, but our legal counsel believes our core argument (the 
legislature cannot by its Vote overturn a right guaranteed by the original charter) is. likely to prevail 
at the appeals level in federal court, in which case a vote to repeal gay marriage in D.C. is likely in 
2010. D.C. is not a state but a city: the battle for the white vote (about 45 percent of the District) 
will be tougher- than in Maine or California. But we will he helped by an emerging new set of 
genuine black leaders who are upset their voices and values have been ignored by the culturally 
liberal white elites. 

Schubert Flint's. preliminary campaign budget suggests Stand for Marriage DC. will need to raise 
around $6 million for victory, NOM will pledge to raise one^third of that budget ($2 million). 



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National Strategy for Winning the Marriage Battle 



2009-2010 Budget: District of edlumi3[a-501 (c)(4) .......... $2,000,000 

Need I...'....'...-.,..: •, $1,000,000 



Iowa 

We are in the process of hiring a full-time political' organizer to identify key races in Iowa, begin 
candidate recruitrnent, and to manage our overall efforts in Iowa. We know that there are key 
opportunities in Iowa, and have been working closely with Congressman Steve King to lay out a 
plan to flip the Iowa legislature. This money will be used to hire a full-time employee, set-up and 
administer an office, and to deal with the legal obligations in creating and administering a state 
political action committee. 

Because gay marriage was imposed via a state supreme court decision, reversing gay marriage in 
Iowa will not be a quick or easy process. It will require electing a new legislature and then votes in 
two successive years to refer a marriage amendment to a vote of the people. 



In theprocess however, by keeping the marriage issue front and center in Iowa politics, we will 
influence the 2012 presidential, campaign indirectly, and emerge with important political assets 
that will serve candidates who articulate a strong marriage message. 



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3. 



Going on Offense 



One of the strategic challenges NOM has faced is that we are playing on our opponents' home turf, 
fighting back efforts to impose gay marriage and striving to protect religious liberty in blue states. 

We have managed to expand our donor and activist base rapidly in spite of the fact that bur core 
activities have been in liberal states. But a strategic goal of NOM is to break out of this cycle, 
building the organization, expanding our donor base, and energizing our grassroots by pushing 
for marriage amendments in red and purple, states, including Pennsylvania, North Carolina, West 
Virginia and Indiana. 



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National Strategy for Winning the Marriage Battle 



The Pennsylvania and Beyond Project 

Local pro-marriage groups in states like Pennsylvania have relied on diffuse public opinion rather 
than sophisticated political organizing to push marriage amendments in these states. To add political 
muscle to our movement, NOM works with local groups while using sophisticated technology to 
reach out to Voters, supplemented by persuasive radio, TV, and internet advertising to (a) identify 
the marriage voters for future electoral purposes, (b) generate phone calls to legislators from 
constituents, and (c) fundrai.se. In North Carolina, we will use a marriage amendment to identify 
our voters throughout the state, not only to push a marriage amendment, but to permit us to rum 
outour voters for the judicial elections there in 2010. Opportunities to push marriage amendments 
may also arise in states like West Virginia and Indiana, where politicians have been blocking 
marriage amendments from getting to the ballot. 



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2010 Neeri...,.,,. .:.„,., ,««.,..-.-..+,-« 






...$1,500,000 

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NOM Rhode Island 

NOM has a unique investment in Rhode Island. Thanks to strong support from an impressive 
network of local leaders, NOM has formed its first truly functioning state chapter. (In most states, 
NOM acts, from and out of the national office, serving as a liaison with independent local groups). 

Under the capable leadership of NOM Rhode Island's executive director Chris Plante (and with an 
impressive advisory board that includes Dr. David Carlin, a professor at CCRI-Newport and the 
former senate majority leader in Rhode Island, Providence Bishop Thomas Tobin, noted prblife 
"super lawyer" Joseph Cavanaugh> pediatrician Michelle Cretella, formerpresident of the Rhode 
Island Psychiatric Society Daniel Harrop, and Brown University Professor Ralph Miech), NOM 
Rhode Island achievements include stopping four bills that would have either directly legalized 
homosexual marriage in the state or paved the way for its introduction through judicial decrees. 

In 2009, NOM Rhode Island has succeeded in building effective coalitions, and partnerships. In 
August, NOM Rhode Island, hosted the First Annual "Celebrate Marriage and Family Day" which 
was attended by over 800 people. NOM Rhode. Island has strengthened its relationship with the 
Diocese of Providence on many levels,, including partnering with the Human Life Guild to king 
marriage education to the Diocesan High Schools around Rhode Island. 



14 



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National Strategy for Winning the Marriage Battle 



Through its Advisory Board, NOM Rhode Island has also made significant progress in mobilizing 
Evangelical congregations in Rhode Island and Southeastern Massachusetts. Finally, the fourth 
quarter of 2009 witnessed the development of a working partnership between NOM Rhode Island 
and national organizations including the Family Research Councif and the Alliance Defense Fund.' 

With the legislative success from the 2009 legislative session and these strong and effective 
partnerships, as well as with the national momentum to protect marriage, NOM Rhode Island is 
well positioned for the 2010 legislative session and election cycle. 

Gay marriage advocates are waiting until 2011, after the retirement of Gov. Don Carcieri, before 
pushing a gay marriage bill in Rhode Island. NOM Rhode Island plans to organize an effective 
donor/activist base, using the successful New Jersey/New York model, to be in a strong position 
to fight gay marriage. , 

In addition to opposing legislative attacks on marriage and family during. 2010, NOM Rhode 
Island expects to be positive and proactive in at least two ways. First, we will introduce and 
support legislation to authorize a Constitutional Amendment to define marriage as between one 
man and one woman. Second, NOM Rhode Island hopes to introduce divorce reform legislation in 
an effort to'strengthen Rhode Island's marriages and families. 

The 2010 election cycle Will be crucial in defending marriage in the long-term in Rhode Island. 
Through its Political Action Committee and (c)(4) arms, NOM Rhode Island plans to take at 
least three seats in the RI House of Representatives from homosexual-marriage supporters, while 
protecting marriage's champions. At the same time,- early rumors indicate that up to ten seats in 
the House will be vacant in November 2010. This provides supporters of marriage and family an 
unprecedented opportunity to protect these institutions for the foreseeable future. v 

NOM 2009-2010 Budget: MORS Rhode Isiatrd-SO^c)^,)..,, $225,000 

2010 Need...; ; >.....: - -.- $225,000 



Confidential 



15 



fei|onaI-&iiateM 



Two Million for Marriage 

The goal of the Two Million for Marriage effort is to use the Obama administration's priority of 
the repeal of DOMA to rally a nationwide donor and activist base, recruiting two million activists 
and 50,000. donors by the election of 2010. We have already launched a $1 million e-mail, direct 
mail, and automated call campaign and have gained over 500,000 activists and roughly 20,000.. 
new donors in our first few months, of this effort Senator Rick Santorum has served as the face of 
this effort through e-mail and direct mail. Senator Santorum has recently agreed to use his voice in 
a nationwide automated call effort to solicit activists and donations. An additional $2 million will 
allow us to reach our goal of two million activists and an additional 20,000 donors by March of 
2010 — well before our own timetable of the election of 2010. 



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2010 Need..,.-... *,... *-*..- 



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State Emergency Reserve Fund . 

We have to be ready for a decisive, rapid and effective response in whatever states gay marriage 
advocates decide to act to push gay marriage. Such- a state emergency fund will also act as a 
discouragement to politicians tempted by their base to push this divisive issue on their constituents. 

Given the threats of intimidation to donors who support marriage in California and nationwide, 
we face a serious hurdle in getting state ballot initiatives and candidate campaigns funded because 
donors must be disclosed. However, if NOM makes a contribution from its own resources that are 
not specifically designated for one of these efforts donor identities are NOT disclosed. It is critical 
that we have a reserve fund to give to these efforts to ensure victory and protect donor identity. Our 
goal is to raise $2 million for this reserve fund before the 2010 elections. 



NOM 2009-2010 Budget: State Emergency Fuhd-501 (c)(4).,... $2,000,000 

2010 Need $1,500,000 



16 



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National" Strategy for Winning the Marriage Battle 



Federal Marriage Political Action Committee 

As we build assets in specific states (identifying marriage voters, activists and small donors) we 
want to direct these assets to electing pro-marriage legislators in Congress. A Federal Marriage 
Political Action Committee (PAC) will help us block the repeal of the Defense of Marriage Act, 
influence Supreme Court nominations* and promote a federal marriage amendment. We will be 
launching- a federal PAC in the spring of 2010. 

Building a network of regional political directors will help us identify and recruit candidates. 
Politically significant states (besides New Hampshire and Iowa) in Senate and presidential politics 
include: South Carolina, Florida, Ohio, Minnesota, Indiana, Pennsylvania, Nevada, Connecticut, 
New Mexico, Nevada, Colorado, and Michigan. 



Because of NOM's unique structure, we. can spend unlimited funds through our 501(c)(4) toward 
promoting, the PAC to our current (30,000) financial supporters. 



WM 2809-201 Gadget: Fetf&ral W&rpagS 

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4. The International Organization for Marriage 

The movement for gay marriage is global. The counterrevolution protecting marriage needs to 
have a similar international reach. We need to take what we have learned about winning marriage 
battles in the U.S. and assist groups .fighting marriage battles in other nations. 

NOM has been approached by leaders in Mexico, Argentina, and Ireland (for example) . for 
assistance in fighting gay marriage battles. We are investing resources now in exploring the legal 
and technological infrastructures needed to export- NOM's successful model to other countries. 
Expenditures in other countries will have to come from international donors. NOM's money from 
U.S. donors will remain fully committed to NOM's national battles. 



17 



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National Strategy for Winning the Marriage Battle 



The goal is to inexpensively leverage the hard-fought knowledge, techniques, experts, messaging, 
and other resources learned in U.S. victories to build a truly global counterrevolution on marriage. 

A very small budget item (for proper, legal advice) will create new global possibilities. As interested 
donors are identified in relevant countries, this budget could expand. 



International 2009-2010 Budget 50lj(c)f4)....>~...^..... 



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Translation of Key Documents .,.,,..........,...,.,,...^....$5,000 

5. NOM Legal Defense Fund 



NOM's successful efforts make ballot box and legislative victories more and more remote for 
"gay marriage" advocates. Once again they are turning to courts to impose tibeir will. NOM has 
been asked to help fundraise for the costs of legally protecting the political victories we have 
helped win with these constitutional marriage amendments. Before us right now is the expensive 
litigation over Prop 8 itself (Perry v Schwarzenegger). The leadership of the Proposition 8 Legal 
Defense Fund and the California Catholic Conference has asked us to help. This may be the' 
' foundational case for protecting traditional marriage at the U.S. Supreme Court. NOM is also 
a client in federal litigation to protect the rights of donors in Prop 8 (ProtectMarriage.com v. 
Bowen), as well as Maine (National Organization for Marriage v. McKee) and elsewhere. 

NOM's goal in 201 is to raise $3 million for the NOM Legal Defense Fund. These funds will 
be turned directly over to the key legal fights for marriage and donor privacy in California and 
elsewhere. 



2010 Budget: Legal Defense Fund... 



■ ■'■«'(,«'#'»».'*»*■■■ ■N»>«»t*«"l! »>»"»«««•< 



.. $3,000,000 



18 



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National Strategy for Winning the Marriage Battle 



6. Cultural Strategies 

Grassroots activism which can generate real political impact is an important "missing ingredient" 
among social conservatives generally and on the marriage issue particularly. Building such a 
capacity is a key part of NOM's strategy for victory. . • 

But to win the marriage debate will require more: innovative cultural strategies to hold and expand 
our base of committed marriage supporters — especially among influential elites and the next 
generation. 

NOM's cultural strategy has a special focus on. the next generation. We understand that the 
transmission of basic moral values across generations involves more than rational argument, 
especially in an age where the market, academia, media and Hollywood conspire to present 
intellectually shallow but emotionally appealing arguments and images for gay marriage. 

Values and character are transmitted through the related processes of emotional engagement and 
identity formation, as well, as rational argument. People ask not only, "What do I cognitiveiy 
believe about right and wrong?" but also "Whom do I aspire to be like?" "What and who makes 
me feel good about the Good?" 

Reason influences emotional commitments, but emotional commitments give rise to rationalizations 
as well. People avoid adopting views that strike them as painful and are attracted to adopting 
reasons for views that provide emotional satisfaction. 

We also recognize that reason influences people not only directly (though the power of argument), 
but indirectly, through the social prestige attached to intelligence and to intellectual elites. The 
good and the true and the beautiful each have their power, and that power is greatest and most 
persuasive when they are made mutually reinforcing. 



NOM's ambitious cultural strategies project aims at influencing, sustaining, reinforcing and 
expanding these basic processes implicated in character formation, with special attention to identity 
and emotional impact. We are looking for a new set of messengers and a new, more emotionally 
powerful set of messages on the marriage issue: Whom will r hurt if I abandon marriage? For 
whom am I standing in standing for marriage? 



19 



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National Strategy for Winning the Marriage Battle 



Here's the bottom line: Hollywood with its cultural biases is far bigger than we can hope to be. We 
recognize this. But we also recognize the opportunity— the disproportionate potential impact of 
proactively seeking to gather and connect a community of artists, athletes, writers, beauty queens 
and other glamorous noncognitive elites across national boundaries. When people are isolated they 
are silent and ineffectual; in community they gather courage and also give courage (by being visible 
to others); Precisely because Hollywood is currently so massively biased, there is an opportunity 
for a small countercultural community to have a disproportionate cultural impact. 



The Latino Project: A Pan-American Strategy 

The Latino vote in America is a key swing vote, and will be even more so in the future because of 
demographic growth. Will the process of assimilation to the dominant Anglo culture lead Hispanics 
to abandon traditional family values? We can interrupt this process of assimilation by making 
support for marriage a key badge of Latino identity. 

We aim to identify young Latino and Latina leaders, especially artists, actors, musicians, athletes, 
writers, and other celebrities willing to stand for marriage, regardless of national boundaries. (For 
example: Eduardo Verastegui, the young actor.who starred in Bella, has come to us offering to be 
a major spokesperson, on marriage; we have also met with a former Miss Mexico in preliminary 
work on this project.) Here's our insight: The number of "glamorous" people willing to buck 
the powerful forces to speak for marriage may be small in any one country. But by searching for 
these leaders across national boundaries we will assemble a community of next generation Latino 
leaders that Hispanics and other next generation elites in this county can aspire to be like. (As 
"ethnic rebels" such spokespeople will also have an appeal across racial lines, especially to young 
urbans in America). 

With the help of Schubert Flint Public Affairs, we will develop Spanish language radio and TV ads, 
as well as pamphlets, YouTube videos, and church handouts and popular songs. Our ultimate goal 
is to make opposition.to gay marriage an identity marker, a badge of youth rebellion to conformist 
assimilation to the bad side of "Anglo" culture. 



20 



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National Strategy for Winning the Marriage Battle 



Latino Project 2010 Budget: $1 mfllion 

Hispanic Outreach coordinator [$75.k. plus benefits]......,.......,.,. $90,000 

Travel budget for coordinator.., ; .-. -•:•- ■■■■■< $35,000 

Radio and TV ad development (Schubert Flint) $40,000 

Radio and TV Production .....> ,.,.... ■■« >■■-■■■ $5^000 

Spanish radio and TV ads.,...,... , - ~ $500,000 

YouTube. productions/viral marketing outreach: ..,...,, .„*.-,....-. $50,000 

PR Outreach to Hispanic TV, radio, printand onl|ne;pu:bljcatiorts' 

[3-4 rrjanths @ $T0k/m©nth .,.,„..:. ..-.,« , .,..«..^^„ w „...».. $35,000 

Hispanic outreach for Rutinn^itut^alti^ 

generation leaders conferences (schofe^hips to confef^cje, travel 

by conference organizes -to. mestwith^ $50,000: 



Phone outreach (iMkocaliinglto Lafeo^ codes, r ;^ ,..*,,.,. ,.,.^< $75, 

Direct rfiaii and email outreach .;.:,'..; ^.^...........^L, ,.,.,..., #5*00.0 



The Next Generation Leaders Project 

By conducting student conferences, speakers and debates,, we aim to find, train; and equip young 
leaders on the marriage issue at Ivy League and equivalent universities.. NOM has launched the 
Ruth Institute for this purpose and is working with the Love and Fidelity Network to replicate the 
success of the Anscombe Model oh the Princeton Campus at other Ivy League schools. 

The Ruth Institute, an arm of NOM headed by Dr. Jennifer Roback Morse, will sponsor two to 
three next generation leaders training, sessions on marriage each year. (The first such prototype 
conference was held August 6 in San Diego.) 

21 

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National Strategy for Winning the Marriage Battle 



Love and Fidelity Network, centered at Princeton, is building a network of chastity-supportive 
organizations at. Ivy League colleges. The centerpiece of LFN's networks' is an annual student 
conference that draws 200 to 300 leaders from Ivy League and equivalent universities. NOM will 
"piggyback" on these existing conferences (and search for other similar venues) to identify, train, • 
and equip next generation leaders on marriage, including media training. 

But in keeping with the aims of the Cultural .Strategies Project we will not confine our mission to 
attract and cultivate a community of cognitive elites alone. Through the Love and Fidelity Film 
Festival and YouTube and Song contest, we will seek to identify a next generation of elites capable 
of creating pro-marriage culture more broadly construed. 

Next Generation 2Q10 Budget: $0QQ,M mitJien 

Two student conferences with Ruth institute; 

[$30k each conference] ...,^. v ..<.„ .>.-«...,...>-. ^«^..,,.,,,.,^„^ 

Marriage and media training at bove-aid 'Riii1ity"NetHQrk . 

. conf etetices ~... ,.,;„>....■.. -.<,,.,>■; ^.^,»^.i. >...■... .■..-.,.#.<•■■■<■■+»■■■■■***'■•■*'*'" 



. Love and Fidelity ad confess '(Y0ui^eat^#©;#$ r .,,v,..,,.,;^.w- : $2CJ,0GQ 
Love and Fidelity Youtu.be, Film and ^ng'F^jvaland Ooritest .„ $1Q:G/aCSQ 

Website maintenance,; email outreach to eoljege students ,«. $50,000 

NOM youth coordinator [$35k plus benefits] , , >,. $.45,000 . 

SUBTOTAL «...;.„.^ ..... .... -. .....^..,..^. $30O,G$Q 

"Not A CM -Right* Project 

The majority of African-Americans, like the majority of Americans, oppose gay marriage, but 
Democratic power bosses are increasingly inclined to privilege the concerns of gay rights groups 
over the values of African-Americans. A strategic goal of this project is to amplify the voice and 
the power of bjack Americans within the Democratic Party. 

22 

Confidential 



^tionalStM^ 



We aim to find, equip, energize and connect African-American spokespeople for marriage; to. 
develop a media campaign around their objections to gay marriage as a civil right. No politician 
wants to take up and push an issue that splits the base of the party. 

"No* A Civil Rigwt" 2010 Butigefc $1 million 

Radio and TV ad production , „..,<.,...,... $100,000 

Media buys / direct outreach ' 

(targeted radio/TV ads and robocalling in blaek neighborhoods 

in. NJ, m, North Carolina, and other key battlegrounds), , $7&>,O00 

Africah-Amet lean outreach to next generation leaders conferences 

(scholarships to conference, travel by conference organizers to 

meet with leaders)... ,,... , .■ ,,; ,>.^.., :i ^w ..,„.„.....,.,.. $50,000 



Black ^loggers project. George ®ojt>a|eid:lie'w^ it? using; small 
amounts of money Id shape the .digeourse>^n1he^erpet^.^...^ 

NQM Africart-Amencah: dtitreaoh coo^ina^oi^^esBefsfon 

plus benefits].. .,>..,;„>,. ..,,... ......,.,....,: ....^. ...'...,.« >.„ 



DUD I V 1 ft"" ii»ftttMa.«sVa««'i'H*lLiiV*»B* 



«■« «■'■.■■-■> k »kp.-p'W«* » »■■«•■:« ■»«<,•»■«* h-»«"»n»-m i*ii*i'»Vhiir'p:***«* U mm ■.*.»*>;*'■ 



$1^0^001 



Expert Witness Project 

Identify and nurture a worldwide community of highly credentialed intellectuals and professional 
scholars, physicians, psychiatrists, social worker's, and writers to credential our concerns and to 
interrupt the silencing that takes place in the academy around gay marriage and related family 
issues. Marriage as the union of husband and wife has deep grounding in human nature, and is 
supported by serious social science. 

Expert Witness Project 2010 Budget: $50,000 



Confidential 



23 



National Strategy for Winning the Marriage Battle 



Catholic Ckrgy Project , 

All clergy are key influencers on gay marriage, but Catholics are a key swing vote and Catholic 
clergy are notoriously difficult to personally reach. The Catholic Clergy Project aims touseNOM's 
close relationships with Catholic bishops to equip, energize arid moralize Catholic priests on the 
marriage, issue. NOM has provided this service to bishops in New York, New Jersey, Rhode Island, 
Iowa, and Kansas to date. 



Catholic Clergy Prcpst WO Budget: $£0$$® 

10 cfergy seminars in 2010 [10 seminars @$S-$00 eaeti.1 ..,..„ - 

SUBTQTA1 ........ ......^.......i... ^....,....«.>...«™.^-"'-^y...^^««.$50jGOO 



Behind Enemy Lines: Document the Victims— Keeping Gay Marriage 
Controversial in Massachusetts, Vermont) and Connecticut 

Document the consequences of gay marriage, and develop, an effective culture of resistance. Polling 
data in Massachusetts indicate that six years after courts imposed gay marriage, public opposition 
to gay marriage remains surprisingly strong. It is also, however, very quiet, in part because people 
fear retaliation, and harassment if they speak up for traditional marriage ideas. (In a recent poll 36 
percent of people who oppose gay marriage agreed that "if you speak out against gay marriage in 
Massachusetts you really have to watch your back because some people may try to hurt you." 10 ) 

Fund a low-cost media campaign (primarily billboards) to support the idea that children need 
mothers and fathers and to highlight threats and promise support to any citizens attacked for their 
pro-marriage views; commission polling and other studies to document consequences of gay 
marriage; and gather a rapid-response team of yideographers and reporters to collect and record 
stories of those who have been harassed,- threatened or intimidated as a result of their support for 
traditional views on marriage and sexuality across the country and also in Europe and abroad. 



24 



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National Strategy for Winning the Marriage Battle 



Behind Enemy Lines 2010 Budget: $300,000 

Polling for intimidation effect in gay marriage/civil union regimes 
[$10k:eacfi poll x 6 polls] „.....;...,....; ,.........:.„:.: $60,000 

Study of what schools are teaching in gay marriage/civil union regimes 
[$25k each X4 states/regions] :.. <. • ■■• $100,000 

PR to maximize polling/studies impact 

[6 months x$15k/month] ,...„.... < ..-.$90,000. 

Billboards and radio media campaign [$$0k/year] » ». $50,000 

SUBT0TIAL *.,..,.„..< —^ «<,i.*>....*»i*.*..***,.»~ . ik v.,.,«*....... i .,r $3fQ r 00iQ 



The Face of the Victims: Rapid Response Video Team and Archive 

Who is hurt by gay marriage? The rapid response video project would aim to put an emotionally 

compelling face on the answer to this question. 

When the government punishes some Methodists because they don't allow gay union ceremonies 
on their own property, we need to capture not only the facts, but the stories— the faces, the names, 
the emotions of the people threatened with litigation. ? 

When a young Michigan grad students gets kicked out of her. school program a few weeks before 
graduation (as happened this past spring) because she won't personally counsel a gay couple on 
how they can keep their relationship together, we need more than her story— we need her face, her 
voice, her outrage and her suffering on camera. 

When a young Hispanic mother discovers in New Jersey what her first grader is being taught 
about gay marriage, how does the school counselor respond to her concerns? We need to get her 
on camera, telling the story of what gay marriage really means . . 

NOM's rapid response team takes the "document the victims" project national, giving us the 
capacity to capture the oppression of people's rights, the disregard of their feelings and interests, 
on video, as it happens, in real time. 



25 



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National Strategy for Winning the Marriage Battle 



NOM will contract with a firm (most likely-Syndicate Pictures out of Philadelphia) to have a team 
on retainer ready to fly out at short notice when news stories like these (most of which never hit 
the national media) occur. 

The Face of f he Victims Pmjmit 201© Bitfdtget: $1S0,0BO 

10 videos [$5000 each] , ..... , $50,000 

Viral marketing of these videos for fundfaising, activist and 
lirtft messaging purposes .,,....:..;.. :... ....,„...,... $55,000 



Professional PR for print/media outreach 

[3 months® $15fe/mo:nth) ,......,,,.,., *.„..,....-,.:., .,, v., $45,000: 

SUBTOTAL^...,.-.. -.-,..,..'..^,^** ;,..,..^.....*.,,..,. $150,000 

Gay Rights or Parents' Rights? An Exploratory Project 

Building on our "behind enemy lines" and "face of the victim" projects, NOM will inaugurate a 
special effort to focus on the consequences of gay marriage for parental rights. 

Study what schools are teaching on gay; marriage .in MA, VT And dT 
[covered above -Behind Enemy Lines ;pr£>|e^|...,, ,,..*.« , — ....$0 



Voices of parents with public school chiWren 

[covered above - Face of the Victims proJeStj; , .,.„,..,..,. $0 

Polling on parents concerns [1 national pel) and 4 state polls! *.- $60,000 

. Children of same-sex couples and their concerns—outreach coordinator 
to identify children of gay parents willing to speak on camera 
[$50k plus benefits] : '. $60,000 

Professional PR for print/media outreach 

[2 months @ $15k/month) $30,000 

SUBTOTAL .....$150,060 

26 

Confidential 



National Strategy for Winning the Marriage Battle 



Achieving NOM's $20 Million Strategy for Victory 

In the little over two years since NOM was founded, it has grown to over 30,000 members with 
an annual operating budget of approximately $10 million dollars in 2009. We have leveraged our 
limited resources to win major victories — most visibly in California and Main© — but also in New 
York, New Jersey, Arizona and Florida. Yet in the legislative and cultural battles that confront us 
we are being heavily outspent — and without greater resources we risk losing marriage on these 
key battlefronts. 

The disparity of resources is overwhelming and clear.. The Human Rights Campaign alone, our 
leading national opposition group, has an annual budget of over $40 million. The Gill Foundation, 
a 501(c)(3) organization, has ah annual budget approaching $20 million, and the Gill Action Fund 
adds $ 1 0-$ 1 5 million more each year in (c)(4) money. 

In addition, supporters of same-sex marriage have a multiplicity of smaller organizations funding 
their efforts on the political level, whereas NOM is the only premarriage organization creating and 
sustaining political action committees at the state level. We will be launching a federal political 
action committee in the spring of 201 0. 

Yet, the nearly $40 million donated to the Proposition 8 effort last year clearly shows that our 
donors can be. motivated to raise large sums of money if the proper plan is put in place. 



27 



Confidential 



28 



National Strategy for Winning the Marriage Battle ' 



Budget & Fimdraising (July 2009 to Dec. 2010) 



Project 



Overall 2009 

Budget Expenditures 



2010 Funds 
Allocated 



Remaining 
2010 Needs 



New York / New Jersey - 50 1 (c)(4) 



$2,000,000 ' $1,200,000 



$0 



$800,000 



Maine ~5Q.l(i? 



i0Q0$;< %M0M 



New Hampshire- 501(c)(4) 



2,000,000 



200,000 



200,000 



1,600,000 



District of Columbia - 501£qp 



''\0&j$m 



'.'" i*||M ; ""'. l^Qptf 



Iowa- 501(c)(4) 



1,000,000 



300,000 



700,000 



.Pennsylvania <£ Beyond - gOX^(4j • 



iM^M: 



Hfio:- 



i,W®M0. 



NOM Rhode Island - 501 (p)(4) 



225,000 



225,000 



^^i'^tjpri-'fbfMan'iap™ 



&$m 



p$->, ^000 



•i- •-»■ 



m 



State Emergency Fund - 501(c)(4) 



2,000,000 



500,000 



1,500,000 



.- j$m 






■ ; ipiptj 



International Organization for Marriage 



25,000 



' 25,000 



MQM Legal, defense Fund; 



', %&$&$„. 



i j ' 



. •< ./ < 



&■• . \3$s$jffl 



Cultural Strategies 



3,000,000 



500,000 



2,500,000 



TOTii- 



"$!&^01o/ir ,<$4M0,WW ■■■$$%$!$$"■ 1$M$$<P 



Confidential 



29 



National Strategy for Winning the Marriage Battle 



$20 Million for Marriage Fundraising Plan 

We have hired Steve Under, the Finance Director for the Proposition 8 effort, to help manage the 
fundraising for.our $20 million campaign. . 

Luis Tellez, Brian Brown, Maggie Gallagher* and Steve Linder will serve on the fundraising 
committee. ' 

NOM's growth, over just the past two years, can be seen below: 



NOM Donor Growth (2007-2009) 



30000 
25000 
20000 
15000 
1000Q 
5000 






2007 
(July - Dec) 


2008 


2009 


Doiuars 
(cuiiju)ative,) 


m ■ ■ • 


$$5g ' . ''' 


' : WM%' '■': 



30 



Confidential 



National Strategy for Winning the Marriage Battle 



Major Donors 

NOM currently has 66 major donors contributing more than $5,000, including 30 donors at the 
$25,000 level, 1 1 donors at the $100,000 level, and 3 donors at the $1 million level. 





$5,000+ 


: $l5,ooo+ 


$100,000+ 


$1,000,000 


©(jn'ofcs 


% , 


'$&'/] 


tt • 


■ 3 













For the campaign, we have a three-stage plan to reach Our goal of $20 million by the end of 20 1 0. 
We' have already cleared the initial phase. Our goal was to raise at least $5 million from a small 
group of our largest donors. That accomplished, we planned to use that momentum to motivate and 
move our donors to increase their past giving to help raise an additional $5 million. 

As with a traditional capital campaign, we have initially focused on our largest supporters to get us 
the seed money necessary to encourage our other major donors to step, up to the plate . 

Wehave now raised a total of $7.5 million from our largest supporters, surpassing our $5 million 
goal, and putting us in an excellent position as we begin Phase 2 of the fundraising plan. Having 
crossed the $5 million threshold we now turn our focus to supporters whose past giving indicates 
that they can make a $ 1 00,000 plus gift. 

We have identified 36 such individuals or foundations. Some of these individuals may do 
significantly more or less than this goal, but conservatively, we believe we can raise at least $3 
million by March 3 1 from these larger donors. 

We will also focus on the 65 donors we have identified as possibly giving $50,000 or larger gift. 
We believe we can raise an additional $2 million from this group by the end of March. 

Once we hit the $ 1 million mark we will go public with the fundraising for the effort at the end of 
March 2010. We will then focus our efforts on a major donor direct mail effort that announces us 
clearing the $10 million hurdle and asks for larger gifts from our $500-$5,000 donors. 



31 



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National Strategy for Winning the Marriage Battle 



Private Phases 

Phase 1 Goal: $5,000,000— Completion Date: January 1,2010 
Phase 2 Goal: $.10,000,000— Completion Date: April 1, 2010 

Public Phase 

Phase 3 Goal: To $20,000,000— Completion Date: December 31, 2010 



How Can We Possibly Do AH This? A Note to Donors 

At NOM, we quickly learned that we cannot in the course of just a few years match the network 
of organizations the gay rights movement has built up over 30 years brick for brick, employee for. 
employee, or dollar for dollar. The top ten gay rights organizations have $200 million in annual 
revenues — plus inestimable advantages in media and entertainment and academia. 

To expand rapidly to meet the urgent need, NOM has adopted two complementary strategies: First, 
NOM- is partnering with "sister organizations" with whom we have strong personal arid mission 
relationships to extend the impact of what NOM can do directly. (Love and Fidelity Network and 
Ruth Institute are examples.) 

Second, NOM has adopted an outsourcing model that allows us to use high-level talent from 
around the country as heeded, rather than build a large, expensive, difficult-to-manage, "tank" in- 
house. We have developed ongoing relationships with some of the best contractors in the country 
who are committed to NOM's mission to do many of the projects outlined, working under our 
leadership, mission focus, and accumulating messaging expertise. This allows us to expand rapidly 
to meet mission objectives while "outsourcing" certain management headaches (like hiring junior 
staffers). 

For example: Our PR needs are served by Creative Response Concepts, considered the premier 
conservative PR firm in the country. Their services can be expanded or shrunk on short notice to 
cope with mission needs. 



32 



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National Strategy for Winning the Marriage Battle 



Our television and radio ads are developed by the team of Schubert Flint Public Affairs, campaign 
managers for Prop 8. They also handle ad placement, and offer strategic and political insight and 
serve as our national campaign managers. We can use this team for direct political advocacy, for 
501(c)(4) lobbying ads, and for 501(c)(3). public education media messaging, 

Frank Cannon and Jeff Bell of Capital City Partners in Washington, D.C. help us coordinate our 
national strategy. 

Gabe Joseph's firm, ccAdvertising, handles robocalling and also the live caller solicitation. He 
expands and manages staff to deliver for us on relatively short-notice in different states, depending 
on the volume of calls we need placed. 

At NOM, we have worked hard to find innovative ways to expand capacity while capitalizing on 
our core strategic asset: a brilliant, creative, in-house team of extremely mission-focused experts 
who can spot opportunity, develop innovative strategies to advance the mission,' and create a 
"feedback" information loop that allows us to learn from failure as well as expand on our successes. 



Contributions or gifts to the National Organization for Marriage, a 501(c)(4) organization 
with QNC status, are not tax-deductible. The National Organization for Marriage does not 
accept contributions from business corporations, labor unions, foreign nationals, or federal 
contractors; however, it. may accept contributions from federally registered political action 
committees. Donations may be used for political purposes such as supporting or opposing 
candidates. No funds will be earmarked or reserved for any political purpose. 



Confidential 



34 



National Strategy for Winning the Marriage Battle 



References 



1 See Benjamin Scafidi, The Taxpayer Costs of Divorce and Unwed Childbearing (New York: Institute for American 
Values, 2008). - ' 

2 See, e.g., Letter dated April. 20, 2009 from Professor Thomas Berg (Univ. of St. Thomas Law), Professor Carl 
Esbeck (Univ. of Missouri Law), Professor Robin Fre'twell Wilson (Washington. & Lee Univ. School of Law), 
and Professor Richard W. Gamett (Notre Dame Law) to Speaker Christopher Donovan, Connecticut House of 
Representatives (available at htrp://minoroijusnce.blogs.com/files/letterrto-rep^donovan-re-bill-899-04-20-09.pdf); 
Douglas Laycock, et al., eds., Same-Sex Marriage and Religious Liberty: Emerging Conflicts (New York: Rowman 
& Littlefield, 2008); Maggie Gallagher, Banned in Boston: The Coming Conflict Between Same-Sex Marriage and 
Religious Liberty, The Weekly Standard, May 16, 2006. 

3 See, e.g., Rebecca Cathcart, Donation to Same-Sex Marriage Foes Brings Boycott Calls, The New York Times, 
July 17, 2008, at Al 5; Tami Abdollah & Cara Mia DiMassa, Prop 8 Foes Shift Attention; The Initiatives Backers 
Strongly Object to the New Focus on Boycotts, Los Angeles Times, November 14, 2008, at Al ; Jesse McKinley, 
Theater Director Resigns Amid Gay-Rights Ire, The New York Times, November 13, 2008, at. CI; Jennifer Garza, 
Prop 8 Opponents Target Supporters, The Oregpnian, November 13, 2008; Valerie Richardson, California Prop 8 
Donors Sue for Privacy; Harassment Cited in Case on Campaign Rules, Washington Times, March 23, 2009, at Al . 

4 NOM's initial entry into state-level marriage debate was in the 2007 New Jersey state races, where NOM helped to 
elect two pro-marriage state legislators, and was credited with helping to make same-sex marriage too controversial 
to be taken up by the lanie duck legislature. See NJ Lawmakers Urged to Move on Gay Marriage Bill, 365Gayxom, 
January 10, 2008; Geoff Mulvihill, Gay Marriage Debate Intensifies as Conservatives Get Organized, Associated 
Press.Dec. 15, 2008. 

NOM also played a key role in California's Prop.' 8 campaign, initially helping to ge,t the measure on the ballot and 
eventually becoming the largest single donor to the Prop 8 campaign. Geoff Mulvihill, NJ Group Makes Waves in 
Calif Gay Marriage Debate, Newsdqy, July 27,' 2008; Tasmin Shamma, Princeton-Based Nonprofit was the Top 
Donor to Fight Prop 8, Daily Princetonian, November 19, 2008.. 

This spring, NOM launched its 2009 Northeast Action Plan, aimed at organizing opposition to same-sex marriage 
throughout the Northeast U.S. Despite the recent entry onto the state political scene in these states, NOM has 
worked closely with state groups to fund robocalls, polling, and grassroots organizing activities. See, e.g., Jeremy W. 
Peters, Group Begins Ad Blitz Against Same-Sex Marriage, The New York Times, May 28, 2009, at A22. 

Dovetailing with the state efforts is a $1 .5 million national media campaign aimed at drawing attention to the 
. consequences of same-sex marriage, as people of faith are increasingly denounced as bigots simply because they 
stand up for marriage. Already, hundreds of thousands of people have seen our ads on YouTube, with millions more 
watching the national TV coverage generated by our, ad campaign. See., e.g., NBC Today Show,- Carrie Prejean 
Speaks About Same-Sex Marriage, April 30, 2009; CNN.com, Miss California USA to Appear in Conservative TV 
Ad, April 30, 2009; Valerie Richardson, Finding Her New Cause, Prejean Promotes Marriage, Washington Times, ■ 
April 29,2009, at Al 8. 

5 See Jeffrey M. Jones, Majority of Americans Continue to Oppose Gay Marriage, Gallup Poll, May 27, 2009, 
available at http://wvw.gallup.eom/poll/l 1 8378Majority-Americans-Continue-Oppose-Gay-Marriage.aspx. 



Confidential 



35 



National Strategy {'or Winning the Marriage Battle 



6 See Anemona Hartocollis, "New York's Highest Court to Rule on Gay Marriages," The New York Times, July 4, 
2006 (discussing the friend of the court brief that we filedin New York on behalf of James Q. Wilson and thirteen 
other prominent scholars). Several of the briefs that we prepared and filed are available at www.domawatch.org. See 
also, Marriage and. the Public Good:- Ten Principles (Princeton, NJ: The Witherspbon Institute, 2006), available at 
www.princetonprinciples.com. 

7 Jeremy W. Peters,. "Paterson Sidelined in Push for Same-Sex Marriage," The New York Times, December 4, 2009, 
available at 

http://www nytimes.com/2009/12/04/nyregioa/04marriage.hmil. 

8 Karl Vick, "Gay Marriage Bill Suffers a Decisive Defeat in N.Y. State Senate," Washington Post, December 3,' 
2009,atA09. * 

"Opponents of gay marriage celebrated a decisive vote in the New York State Senate, where a proposal to 
legalize same-sex marriag& was defeated 38 to 24 on Wednesday. 

The .unexpectedly wide margin was delivered in a relatively liberal state where the other chamber of the 
legislature has thrice approved the measure and the governor, David A, Paterson, had been poised to sign it into 
law. The vote prompted pronouncements that the momentum for gay marriage had been not only halted, but 
also effectively reversed. Same-sex marriage is -legal in Iowa, Vermont, Massachusetts, Connecticut and, most 
recently, New Hampshire, where it goes into eflect.Jan. 1, 

"I think you put itall together and it most likely spells the end of the idea that you can pass gay marriage 
democratically anywhere else in the United States," said Maggie Gallagher, president of the National 
Organization for Marriage, which spearheaded opposition, in Albany, "I think the gay marriage lobby will have 
togp back to a court-based approach." '; 

9 James Abeam, Same-Sex Marriage is Likely Over, Tfce Bergen Record, December 16, 2009 ("Legislation 
authorizing same-sex marriages in New Jersey has stalled.in Trenton and is unlikely to pass. The vote. by a Senate 
committee last week to release the bill for a floor vote may be as far as it can go. Its chances in the full chamber 
were so dim that two days later the chief sponsors of the bill withdrew it, before a scheduled vote 

could take place"). 

10 2009 NOM Massachusetts Marriage Survey, Five Years After Goodridge: Gay Marriage Divides Massachusetts 
Voters, May 17, 2009, available at www.nationformarriage.org. 



Confidential 



National Strategy for Winning the Marriage Battir 



Maine Marriage Referendum Campaign Budget 
November, 2009 Election 
Draft 6 - August 1 , 2009 
Recommended Media Levels 




23 



Subtotal, Earned Media 



SFPA 



Subtotal, Campaign Management 



gags 



so 



10,000 



$10,000 



10! 



20,000 






$20,000 



20,000 



$20,000 



30,000 



$30,000 



30,000 



.$30,000 



30,000 



$30,000 



15,000 



$15,000 



155,000 



$146,000 



24 



•25 



26 



$3,500 



$3,500 



$3,500 



$3,500 



$3,500 



$3,500 



$21,000 




Sterling Corporation 



10,000 



10,000 



10,000 



10,000 



10,000 



10,000 



60,000 



Subtotal, Fundralslng 



$0 



$10,000 



$10,000 



$10,000 



$10.000 



$10,000 



$10,000 



$60,000 



27 



Mlso/Contlngency 



$1,000 



$10,000 



$10,000 



$10,000 



$20,000 



$20,000 



$20,000 



$91,000 



Total, Operations Budget 



$64,500 



$220,155 



$330,575 



$209,255 



$222,405 



$276,905 



$86,325 



$1,400.120 



Paid Media Budget 



Direct Mail 




28 



Direct Mail 





150,000 



150.000 



300,000 



Subtotal, Mall 



$0 



$0 



$0 



» 



$150,000 



$150,000 



$0 



$300,000 



Campaign Media (recommended) 



Television (4120 TRPs) 
Cable.(2p60TRPs) 
Radio (2425.TRPS) 
Online Advertising 
Production . 



25,000 



240,785 

123,303 

210,000' 

50|000 

■ 130,000 



361,177 
184,955 
315,000 

i.op.ppo 

130,000 



601,962 
308,258 
525,000 
175,000 
260,000 



Subtotal, Campaign Media 



$0 



$0 



$0 



$25,000 



$754,088 



$1.081,132 



$0 



$1,870,220 



m&®t&88989$Bsmi®B®8i!8&8%* Malaga 



m$$ii$mM 



Subtotal, Paid Media 



$o 



$0 



$0 



$25,000 



$904,088 



$1,241,132 



$0 



$2,170,220 



S&JZ&M>?W$®$ SgjiiKSgi&aS 




#£SSSigS 



$64,500 



$220,155 



$330,575 



$234,255 



$1,126,493, 



$1,518,037 



$86,325 



$3,570,340 



37 



CONFIDENTIAL 



National Organization for Marriage NewJersey Budget 
2009 Election, and Lame Duck Session 
Draft 2 T August 1,2009 



Budget 



Phase One 



Phase Two 



BASE 



RtJbfiFT 



Office/A 



Phone/Fax/Misc. 

Shipping/Prinling/Copies 

Travel 



500 
3,000 



500 
3.000 



500 
3,000 



1,500 
9,000 



Subtotal, Office 



Voter Research 



$4,000 



$4,000 



$4,000 



$12,000 



Baseline Survey 



25,000 



25,000 



Subtotal, Research 



$25,000 



$0 



$0 



$25,000 



Grassroots 



Robo. Calls 

Voter File Match/Enhancement 

Website 



40,000 
25;000 
20.000 



30.000 



30,000 



$85,000 



100.000 
25.000 
,20,000 



$145,000 



Subtotal, Grassroots 



Conferences/Ed Boards 



$30,000 



J30.00Q 



Subtotal, Earned Media 



Legal 



$o 



$2,500 



$0 



$2,500 



$0 



$2,500 



$0 



$7,500 



$2,500 



$5,000 



Consultant 



$5,000 



$12,500 




To 



Subtotal, Fundralsing 



n 



$o 



$o 



$0 



IfliscJContlngency 



$1,000 



$10,000 



$10,000 



$21,000 



Hi 



Total, Operations Budget 



Legislative races 
Governor's race 



$120,000 



50,900 
150,000 



$51,500 



$51,500 



$223,000 



50,000 
150,000 



Subtotal, PAC Contributions 



$200,000 




Direct Mail 



150.000 



50,000 



50.000 



250,000 



Subtotal, Mall 



$0 



$50,000 



$50,000 



$100,000 



Campaign Media 



Television 

Cable 

Radio 

Phone Banking 

Online Advertising/Recruitment 

Production- ■ 



35,000 



O 

325,000 

100.000 

■ 40,000 

35.000 

25.000 





325,000 

100,000 

40,000 

35.000 

25,000 




650.000 
200,000 

80.000 
105.0'OP 

5O.000 



Subtotal, Campaign Media 

mmmmmmmm. 

Subtotal, Paid Media 



$0 



$200,000 



$525,000 $525,000 



$575,000 



$575,000 



$1,085.000 



$1,385,000 



Total Budget 



$320,000 



$626,500 $626,500 



$1,608,000 



38 



CONFIDENTIAL